The new Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (the “Regulations”) make a set of targeted changes to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. Some of the amendments will affect all firms subject to the Regulations, for example in relation to customer due diligence and currencies. Other changes, for example, to crypto-asset businesses and trusts will only be relevant to some firms’ businesses.

As a general resource, the Implementation Guide should not be regarded as a substitute for professional advice, which should still be obtained where appropriate. Further, fund managers should pay close attention to applicable legal or regulatory requirements and guidelines issued by regulatory authorities in applicable jurisdictions, which are likely to be more detailed than the sound practices described in the Implementation Guide.

We would like to thank Citco for sponsoring and for its assistance in preparing this guide.